The plaintiff alleges that
(he/she) was (discharged / disciplined / penalized) by the defendant
because (he/she) reported violation of (state law or regulation /
federal law or regulation / municipal ordinance or regulation) to <name>,
a public body. Connecticut General Statutes § 31-51m provides:

"No employer shall
discharge, discipline or otherwise penalize any employee because the
employee, or a person acting on behalf of the employee, reports,
verbally or in writing, a violation or a suspected violation of any
state or federal law or regulation or any municipal ordinance or
regulation to a public body, or because an employee is requested by
a public body to participate in an investigation, hearing or inquiry
held by that public body, or a court action."

In order to prevail on
(his/her) claim under § 31-51m, the plaintiff must prove by a
preponderance of the evidence that (his/her) (discharge / discipline
/ penalty) was in retaliation for (his/her) report to <name>,
a public body. Retaliation is proved in this case if the plaintiff
demonstrates by a preponderance of the evidence that (his/her)
report was a motivating factor for (his/her) (discharge /discipline
/ penalty) even though other factors also motivated the defendant's
decision to (discharge /discipline / take adverse action) against
(him/her). A "motivating factor" is a factor that made a difference
in the defendant's decision.

The plaintiff does not
have to prove that (his/her) report to <public body> was the
sole or even the principal reason for the decision, as long as
(he/she) proves that (his/her) report was a determinative influence
in the decision. (He/She) may prove retaliation directly by proving
that (his/her) report to <public body> more likely motivated
the defendant's action in (discharging / disciplining / penalizing)
(him/her) or indirectly by proving that the reason[s] given by the
defendant for the (discharge / discipline / penalty) (was/were)
unworthy of belief. If you find that the defendant's stated reasons
are not credible, then considering all the circumstances you may
infer, although you are not required to infer, that the plaintiff's
report to <public body> was a motivating factor in the
defendant's decision, even if it may not have been the only
motivating factor.

It is not your role to
second-guess the defendant's business judgment. The fact that an
employer's decision was incorrect, unfair, unwise or capricious, or
even based on personal favoritism or animosity is irrelevant, as
long as the plaintiff's reporting of the violation was not a
motivating factor that made a difference in its decisions.